DOJ-OGR-00006554.pdf

--- Page 1 --- The image shows a page from a legal document, specifically a court case file. The page is white with black text and has a header at the top that includes the following information: * **Case Number:** 1:20-cr-00330-PAE * **Document Number:** 440 * **Filed Date:** 11/12/21 * **Page Number:** 38 of 40 The main body of the text is divided into sections, including: * **H. The Court Should Be Wary of the Defense Refusal to Address the Government's Motions** * **The defendant has largely refused to respond to the Government's motion to preclude evidence of the defendant's other acts, offering the defendant's own statements, arguments sounding in nullification, or the baseless argument that the defendant was allegedly a victim of Epstein. (Def. Opp. at 49-57). The Court should accordingly preclude the defendant from opening on these subjects or attempting to elicit evidence along these lines unless and until she explains to the Court how this evidence could possibly be admissible.** * **As explained above and in the Government's motion, however, there is significant risk that the defense theories will contravene the Federal Rules of Evidence and the law of the Circuit to put irrelevant matters, such as the Florida investigation, before the jury. The Court should not permit the defense to open on these points without first providing notice so they can be litigated. In particular, the Government does not believe there is a good-faith basis to argue that the defendant was a victim of Epstein, such an argument would be entirely irrelevant, and it may well contravene Rule 12.2 of the Federal Rules of Criminal Procedure. The Court should allow these issues to be litigated in advance, and not at sidebar after the jury has already heard the** The footer at the bottom of the page includes the text "DOJ-OGR-00006554" in small font. Overall, the image appears to be a page from a legal document related to a criminal case, specifically a motion to preclude evidence and a discussion of the defense's refusal to address the government's motions.